Notification to customers about privacy policies and practices at H. C. Denison
Designed to comply with the Gramm-Leach-Bliley Act

Since 1928, our commitment to our customers has remained unchanged. We have always been committed to maintaining the confidentiality, integrity and security of personal information entrusted to us by past, current, and prospective customers. We are very proud of our privacy practices, and we want you to know how we protect your information and how we use it to service your account.

H.C. Denison Co. collects nonpublic personal information about you from the following sources:

• Information we receive from you in person, on applications, or other forms; and
• Information we receive about your transactions with us or others.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.

If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

H.C. Denison Co. restricts access to your personal and account information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your personal information.

Please see our Privacy Promise to you below.

As always, don't hesitate to call your registered representative or myself if you have any questions or concerns.

Sincerely,

James A. Testwuide
President

THE H.C. DENISON CO. PRIVACY PROMISE

While information is the cornerstone of our ability to provide superior service, our most important asset is our customers' trust. Keeping customer information secure, and using it only as our customers would want us to, is a top priority for all of us at H.C. Denison Co.

Here, then, is our promise to our customers:

1. We will safeguard, according to strict standards of security and confidentiality, any information our customers share with us.
2. We will permit only authorized employees, who are trained in the proper handling of information, to have access to the information. Employees who violate our Privacy Promise will be subject to our disciplinary process.
3. We will not reveal customer information to any external organization unless we have previously informed the customer in disclosures or agreements, have been authorized by the customer, or are required by law or our regulators.
4. We will always maintain control over the confidentiality of our customers' information.
5. We will tell customers in plain language, initially and at least once annually, of our privacy policy. The annual notice will be included with the mailing that is sent out every year which provides a copy of our Financial Statement.
6. Whenever we hire other organizations to provide support services, we will require them to conform to our privacy standards.
7. We will attempt to keep customer files complete, up-to-date, and accurate.